The Aviation Environment Federation believes that a third runway at Heathrow would
be severely damaging environmentally and socially, and would have uncertain economic benefits. Similarly, a move to mixed-mode operations will end the Heathrow is within the boundary of Greater London, with residential areas immediately to the north, east and south (and some less concentrated settlements to the west). It already has enormous adverse impacts on many thousands of people in terms of noise, air pollution, climate change, road congestion, visual impacts and accident risk.
In additional to causing significant air and noise pollution impacts, adding a third runway to Heathrow would:
· Lead to the loss of hundreds of homes, including the entire community of Sipson;
· Destroy the social structure of several communities;
· Lead to the loss of 230 hectares of Green Belt land, with associated rights of way and areas of public open space;
· Destroy or severely affect ten historic buildings (e.g. Manor Farm Great Tithe Barn at Harmondsworth) and an Archaeological Priority Area;
· Increase the number of people living within Heathrow’s public safety zones;
· Significantly increase greenhouse gas emissions that contribute to climate change, going directly counter to the government’s climate change targets;
· Disturb birdlife on the nearby South West London Water Bodies Special Protection Area and Ramsar site, and increase air pollution at Wimbledon Common, Burnham Beeches, Windsor Forest and Great Park Special Areas of Conservation. These are internationally important sites which, under the Habitats Directive, require “appropriate assessment” studies to be carried out for any plan or project that could affect their “integrity”;
· Have landscape and visual impacts;
· Add to pressures on energy and water resources.
This response covers the environmental questions posed in the consultation. A supplementary AEF response is being prepared to cover the wider issues such as climate change.
In The Future of Air Transport White Paper, the Government itself recognised the ‘severe environmental disadvantages’ of Heathrow, and put constraints on when it would consider permitting expansion:
§ if the 57 dBA Leq contour would not exceed 127 km2
§ if it “could be confident that” annual mean concentrations of nitrogen dioxide would not exceed 40 µg/m3
The studies supporting the White Paper identified significant problems to achieving these constraints. Since then, additional studies have been carried out, based on recommendations by technical panels set up by the Department for Transport. The studies are extremely detailed and technical. They have been peer reviewed, and an overarching report has been prepared on ‘demonstrating confidence’. They suggest that the constraints above can be overcome.
However the studies are based on a range of assumptions, some of which are very uncertain. They also assume significant improvements in other sectors as a way of balancing out the negative impacts of aviation: some of these improvements may not fully take place. We believe Government would be failing in its duty to protect communities from harmful levels of pollutants unless it can demonstrate not only how it will ensure that the necessary measures are in place to comply with the air quality Directive limit values, but also how it will ensure compliance within the projected margins of error in the projections. Any improvements in noise and air quality should be used to improve people’s quality of life rather than permitting more aircraft to fly from Heathrow.
Furthermore, compliance with the relevant noise and local air quality safeguards needs to be made at each phase of Heathrow’s proposed development. It is insufficient to look at projected operations in 2030 without considering whether there is compliance at regular intervals.
This consultation response considers, in turn:
§ noise impacts
§ air pollution impacts
§ safety issues
§ where BAA ends and Government begins.
NOISE
The Air Transport White Paper notes for Heathrow that:
any further development could only be considered on the basis that it resulted in no net increase in the total area of the 57dBA noise contour compared with summer 2002, a contour area of 127 sq km. [1]
The Civil Aviation Authority (CAA) suggests that 615,000 ATMs are possible in 2020, and 702,000 ATMs in 2030 whilst staying within the agreed noise limit (<127 km2 at <57 dBALeq). The CAA’s impact predictions rely heavily on assumptions about future aircraft, including whole new engine ‘families’ that don’t yet exist. They use information on possible new technologies from the Advisory Council for Aeronautical Research in Europe. We believe that 1. it is unlikely that all of the future noise reductions assumed by the CAA will take place, and 2. LeqdBA is not the (only) correct metric to use in predicting the noise impacts of aviation.
1. Will new technology solve Heathrow’s noise problems?
The industry often points to radical new technology on the horizon that will deliver very substantial future noise reductions. The implication of projects with titles such as the
Quiet Technology Demonstrator Programme is that at some point in the not-too-distant future aircraft noise will simply cease to be a problem. But if a three-runway airport in 2015 or 2020 is to remain within the Government’s contour target for the 57 dBALeq, substantially quieter aircraft will need to have been on the market for some years. Here we examine whether this is likely.
In 2000, the Advisory Council for Aeronautical Research in Europe (ACARE) published its 2020 vision for the air transport industry[2]. In relation to aircraft noise, it set itself ambitious goals to reduce perceived noise by 50% by 2020 relative to 2000, and to eliminate significant aircraft noise outside the airport boundary during the same period. In practical terms, this means reducing noise by 10 EPNdB[3] per take-off, and keeping the 65 LDEN[4] contour within the airport boundary.
These goals are aspirational and present significant challenges to manufacturers and the rest of the industry. The earliest implementation date for any of the technologies emerging from this work is likely to be 2010, by which time ACARE hopes to be able to demonstrate a reduction of 5 EPNdB for existing in-production aircraft as well as new designs.
ACARE has just announced that it has secured 2-years funding from the EU to undertake a comprehensive progress review of the ACARE 2020 goals. Although the review will not commence until spring 2008, we understand that some progress has being made to date. Innovations in nacelle and nozzle liner concepts, inlet design and landing gear[5] are all currently being used in flight tests. However, there is only limited scope for retro-fitting these technologies to the existing fleet (a new engine would probably be required, making it an expensive option), nor do we believe they will be in widespread production by 2010, especially without any global or regional regulatory or economic drivers, an issue enlarged on below.
The vision for 2020 is less clear still. The interim target is based on making marginal improvements to existing technologies, but achieving the full 10 EPNdB reduction will clearly require a new generation of airframes and engines. Such designs might include over-fuselage wings and engines as well as ‘blended-wing’ aircraft, a concept not yet far advanced beyond the drawing board.
Few would disagree that ACARE’s goals will be tough to meet. In fact they will require a faster rate of technological introduction than over the past 20 years, even though it is generally acknowledged that the current generation of technology is now at a stage of offering diminishing returns.
But the crucial point is that ACARE focuses on what the best new technology can achieve, rather than on what the market is likely to demand. Without regulation or stringent standards, uptake is likely to be slow. This is acknowledged in the CAA report, which notes that “full capacity (702,000 ATMs) may not be realised in 2020 without significant incentives to encourage airlines to replace the current large numbers of four-engined aircraft with a greater proportion of large twin-engined aircraft” (p. iv). Most airlines currently using Heathrow have young fleets and significant early fleet replacement is unlikely without substantial incentives or penalties. The Department for Transport has not proposed any such measures, however.
In the short-term, the CAA’s noise report assumes a 25dB decrease in some cases: “The next generation 220-300 seat wide-body airliners are much more mature in design... cumulative certificated noise levels are expected to be around 25dB below Chapter 3 levels” (2.3.11); “the new technology 450 seat aircraft is envisaged to have a cumulative margin relative to Chapter 3 of around 25dB, compared with 16dB for the Boeing 777-300ER.” (2.3.12). Many of these aircraft are already in service. Chapter 3 came into effect in 1977, and by 2006 (the date when Chapter 4 came into force) most in-production aircraft were already capable of delivering significant cumulative reductions.
Is the correct metric being used?
The inadequacy of relying on any single metric was recognised by Government in the first stage of its consultation for the White Paper in 2000, when it acknowledged that ‘no single metric can capture all the characteristics of noise, nor of the annoyance it causes’.[6] Nonetheless, the Government continues to use 57Leq dBA as the indicator for the onset of significant noise annoyance.
The ‘ANASE’ study[7] concluded that there is no noise level at which there is an onset of significant annoyance: every flight triggers some annoyance. ANASE was a complex and ground-breaking study, and it raises uncomfortable conclusions for the Government’s approach to aircraft noise and the adequacy of its policies. We are disappointed that the findings of ANASE were not used in the noise assessment underpinning this consultation despite having access to the results for almost a year prior to publication. In particular, the study suggested that the 57dB figure used by Government to represent the onset of significant annoyance is far too high. Based on a similar percentage of people annoyed, a figure closer to 50dB is more appropriate. This means that far more people are currently affected by aircraft noise than the government currently admits, and far more would be affected in the future by an increase in capacity at Heathrow. Also the ‘economic cost’ of noise currently estimated by the government would also be too low.
Furthermore, we have long argued – and the ANASE study has confirmed - that while contours are a useful comparative tool, the reaction to aircraft noise is highly influenced by the number of noise events. So although average noise levels around Heathrow have decreased over time due to improvements in individual aircraft, many residents now feel more annoyed because of the relentless growth in the number of flights. Similarly, although the 57 dBALeq contour associated with mixed mode operations at Heathrow might have a geographical impact not larger than the 127 sq km maximum area, mixed mode would subject communities to continuous aircraft operations throughout the day, which would undoubtedly increase their annoyance. The importance attached by residents to the predictable half day’s respite from aircraft noise provided by runway alternation cannot be stated strongly enough. Self-evidently, with 702,000 movements, disturbance would be even greater.
The CAA’s noise model assumes no increase in the number of people living under Heathrow’s flight paths after 2006, although major housing and population growth is expected in London and the South East over the next 20 years. This would increase the number of people annoyed by noise from Heathrow.
We believe that the noise climate is already deteriorating at Heathrow. A particular weakness of the Leq system is that it is liable to be distorted by individual noisy events such as Concorde flights, and it should be noted that the contour target stipulated in the White Paper is set with reference to a year when Concorde was still flying. By 2004 Concorde had been retired, with the result that some additional ‘head room’ became available in the contour target.
The difference Concorde makes can readily be quantified from DfT data:[8] an extra two flights per day extend the area of the 57 dBA Leq by almost 20 km2. Since DfT provide a figure for hypothetical extra Concorde flights, it is equally possible to subtract the effect of these flights and estimate the size of the contour had Concorde not been flying at all. This is shown in Table 1. It provides a measure of the performance of the conventional fleet, and a truer indicator of the noise climate.
Table 1: an estimate of noise contours at Heathrow without Concorde (derived from DfT noise contours)
Year / ‘98 / ‘99 / ‘00 / ‘01 / ‘02 / ‘03 / ‘0457 dB Leq (km2) / 125 / 120 / 112 / 115 / 107 / 110 / 116
These figures are approximate, but they are sufficient to illustrate a trend: while the impact of growing numbers of aircraft movements was successfully offset by a hard-and-fast operational restriction (the phase-out of chapter 2 aircraft by 2002), once this was complete the contour began to expand again in line with ATMs – in other words the on-going replacement of aircraft at the margins of the fleet is not enough to offset the effects of growth. What is more, no further phase-out is in prospect: ICAO failed in 2001 to agree on a phase-out of the noisiest Chapter 3 aircraft, and the issue has not been raised since. So once the anomalous effect of Concorde has been set aside, it can be seen that the noise climate, even as measured by the Government’s preferred metric of averaged noise contours, is deteriorating, and the Government has failed to honour its guarantee on noise.